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State of California

Franchise Tax Board

Application for Voluntary Disclosure


Part 1 Representative or Applicant Information
Representatives or Applicants Name Telephone Number

Representatives or Applicants Street Address FAX Number

City State ZIP Code

Part 2 Information Required for Primary Applicant Entity

1. Is the applicant entity organized and existing under the laws of the state of California? . . . . . . . . . . . . Yes No
2. Is the applicant entity qualified or registered with the California Secretary of State? . . . . . . . . . . . . . . Yes No
3. Does the applicant entity maintain and staff a permanent facility in California? . . . . . . . . . . . . . . . . . . Yes No
4. Has the applicant entity or a predecessor entity ever filed a tax return with FTB? . . . . . . . . . . . . . . . . Yes No
5. Has the applicant entity ever been the subject of an inquiry by FTB with respect to potential
liability for income/franchise taxes? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
6. If the applicant entity is a trust, have trust administration activities ever been performed
in California? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
7. If the applicant entity is a trust, are there any California resident beneficiaries
(excluding contingent beneficiaries) of the trust? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If you answered Yes to any of the above questions, STOP. The applicant entity does not qualify for the VDP. If you
answered No to all seven questions, provide the following information:

1. Tax years to be covered by the agreement: ____________________________________________________________

2. Type of entity applying for the Voluntary Disclosure Program (VDP):

C corporation S corporation Limited liability company Trust


3. State the basis you had for believing that you were immune from California tax: ________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________

4. Did you rely upon the advice of a person in a fiduciary position or other competent advisor that you were immune from
California tax? If so, describe the nature of the advice you received, status and competency of the person giving the
advice, and the approximate date that your received the advice:____________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________

5. Provide other information attesting to your good faith and lack of willful neglect in failing to file California tax returns
and pay California taxes:___________________________________________________________________________
_______________________________________________________________________________________________

FTB 4925 c2 (REV 12-2015) PAGE 1


Specific Entity Directions
Corporation defined in Section 23038
Complete Parts 6 through 8. If more than one corporation in a single unitary combined reporting group wishes to
apply for voluntary disclosure relief, each corporation seeking relief must file a separate application, simultaneously
if possible.
S corporation defined in Section 23800
Complete Part 3 for qualified shareholders, in addition to Parts 6 through 8.
LLC not classified as a corporation
Complete Part 4 for qualified members, in addition to Parts 6 through 8.
Trust
Complete Part 5 for qualified beneficiaries, in addition to Parts 6 through 8.

Part 3 Information Required for Secondary Applicants - Qualified Shareholders


1. How many shareholders held an interest in the S corporation during the years to be covered
by the voluntary disclosure application? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
a. How many of those shareholders are individuals? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
Only shareholders who are individuals may enter the VDP.
b. Are all individual shareholders applying in connection with this application currently

California nonresidents? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
Individual shareholders must be also nonresidents on the signing date of the voluntary disclosure
application to be qualified shareholders.
2. Based on the above information, how many qualified shareholders are applying for the VDP in
connection with the qualified S corporation? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
3. State the reason, if any, that any shareholders of the primary S corporation applicant are not
applying for the VDP: ______________________________________________________________________________
4. Will the S corporation be filing a group nonresident return (See FTB Pub. 1067)? . . . . . . . . . . . . . . . . Yes No
5. State the basis the qualified shareholders had for believing that they were immune from California tax: ______________
_______________________________________________________________________________________________
6. Did the qualified shareholders rely upon the advice of a person in a fiduciary position or other
competent advice that they were immune from California tax? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If so, describe the nature of the advice you received, status and competency of the person giving
the advice, and the approximate date you received the advice:______________________________________________
_______________________________________________________________________________________________
7. Provide other information attesting to the qualified shareholders good faith and lack of willful neglect
in failing to file California tax returns and pay California taxes:______________________________________________
_______________________________________________________________________________________________
Qualified S corporation applicants must also complete Parts 6 through 8 below.
Part 4 Information Required for Secondary Applicants - Qualified Members
1. How many members held an interest in the LLC? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
a. Of that amount, how many are individuals, corporations, and other LLCs? . . . . . . . . . . . . . . . . . . _______________
b. Are all individual members that are applying for relief in connection with this application

currently California nonresidents? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Yes No
Individual members must also be nonresidents on the signing date of the voluntary disclosure
application to be qualified members.
c. Are all corporations or LLCs that are applying for relief in connection with this
application not: organized under the laws of California; qualified or registered with the

California Secretary of State? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Yes No
Corporate or LLC members may not enter the VDP if they are organized under the laws of
California, or qualified or registered with the California Secretary of State.

FTB 4925 c2 (REV 12-2015) PAGE 2


2. Based on the foregoing, how many qualified members are applying to enter the VDP in connection
with the qualified LLC?
a. Number of qualified members that are individuals: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
b. Number of qualified members that are corporations: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
c. Number of qualified members that are LLCs: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
3. State the reason, if any, that any members of the primary LLC applicant are not applying for the VDP:
_______________________________________________________________________________________________
4. State the basis the members had for believing that they were immune from California tax:________________________
_______________________________________________________________________________________________
5. Did the members rely upon the advice of a person in a fiduciary position or other competent
advisor that they were immune from California tax? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If so, describe the nature of the advice you received, status and competency of the person giving
the advice, and the approximate date that you received the advice:__________________________________________
_______________________________________________________________________________________________
6. Provide other information attesting to the qualified members good faith and lack of willful neglect
in failing to file California tax returns and pay California taxes:______________________________________________
_______________________________________________________________________________________________
If voluntary disclosure relief is sought for individuals, corporations, and LLCs that held interests indirectly in qualified LLCs
through an interest in an LLC that is a pass-through for tax purposes, attach additional sheets to provide the information
requested above for each entity seeking relief as an indirect owner of an interest in a qualified LLC.
Qualified LLC applicants must also complete Parts 6 through 8 below.
Part 5 Information Required for Secondary Applicants Qualified Beneficiaries

1. How many beneficiaries held an interest in the trust?


a. How many beneficiaries are individuals? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _______________
Only beneficiaries who are individuals may enter the VDP.
b. Have all individual beneficiaries applying in connection with this application been California

nonresidents for the past six years? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
Individual beneficiaries must be nonresidents on the signing date of the voluntary disclosure
application, and for the prior six years, to be qualified beneficiaries.

2. How many qualified beneficiaries are applying to enter the program? . . . . . . . . . . . . . . . . . . . . . . . . . _______________
3. Please state the reason, if any, that any individual beneficiaries are not applying for the VDP:_____________________
_______________________________________________________________________________________________
4. State the basis the beneficiaries had for believing that they were immune from California tax:______________________
_______________________________________________________________________________________________
5. Did the beneficiaries rely upon the advice of a person in a fiduciary position or other
competent advice that they were immune from California tax? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If so, describe the nature of the advice you received, status and competency of the person
giving the advice, and the approximate date that you received the advice:_____________________________________
_______________________________________________________________________________________________
6. Provide other information attesting to the qualified beneficiaries good faith and lack of willful
neglect in failing to file California tax returns and pay California taxes: _______________________________________
_______________________________________________________________________________________________
Qualified trust applicants must also complete Parts 6 through 8 below.

FTB 4925 c2 (REV 12-2015) PAGE 3


Part 6 Exhibit A
Include the following information on a separate sheet labeled Exhibit A, and attach it to your voluntary disclosure
application. Provide the following information:
1. State of incorporation/organization for the primary applicant.
2. Primary applicants line(s) of business and describe its business activities inside and outside California.
3. Tax year the primary applicant began doing business anywhere.
4. Business activity that created California nexus for the primary applicant and tax year it was created.
5. If applicant is a member of a unitary group in which other members are applying for voluntary disclosure, applicants
relationship to each other (parent, subsidiary, brother-sister affiliate).
6. Beginning and ending dates of the primary applicants accounting period.

Part 7 Exhibit B
On a separate sheet labeled Exhibit B, provide the information requested in the manner described below (or in a
comparable manner) for each period to be covered by the voluntary disclosure agreement:
A primary applicant entity, except for a qualified LLC applicant, should include the following information:
Federal taxable income before net operating losses (NOL).
California net income and estimate of California tax due.
Estimated California net income and estimate of California tax due for any qualified shareholders and qualified
beneficiaries applying in connection with the primary applicant entity.
A qualified LLC applicant should state the:
Amount of the LLCs total income from all sources derived from or attributable to California (See R&TC Section 17942).
California net income and the amount, if any, that will be withheld by the LLC for LLC members that do not consent
to California tax jurisdiction (see R&TC Section 18633.5). A members failure to provide its affirmative consent to
jurisdiction under Section 18633.5 does not exempt that member from its California tax obligations.
LLC tax due.
LLC fee due (if any) and an estimate of California tax due from and for all qualified members that are applying for the
VDP in connection with the qualified LLC applicant.
Provide the income and tax information requested above for each applicant entity (primary and secondary) that is not an
LLC in the following format, and indicate if the entity is a primary or secondary applicant:
Tax Year, Starting From Most Recent Federal Taxable
(MM/DD/YYYY MM/DD/YYYY) Income Before NOLs CA Net Income Estimate of CA Tax Due

FTB 4925 c2 (REV 12-2015) PAGE 4


Provide the income and tax information requested above for each LLC applicant (primary and secondary, direct or indirect)
in the following format, and indicate if the entity is a primary or secondary applicant:
Tax Year, Starting From R&TC 17942 Total Withholding Amounts
Most Recent Income from CA LLC Fee Under 18633.5
(MM/DD/YYYY MM/DD/YYYY) Sources R&TC 17941 LLC Tax ($800) (if applicable) (if applicable)

Part 8 Signature
Failure to provide all requested information and to promptly respond to FTB inquiries concerning your
application will delay processing and may result in the application being denied.
I declare under penalty of perjury under the laws of the state of California that I am the applicant, or authorized
by the unnamed applicant(s) to act as its agent in applying for the Voluntary Disclosure Program, and that the
information given above and in the attached Exhibit A, Exhibit B, and any supplemental information is true and
correct to the best of my knowledge and belief.
Print Name

Signature Date

FTB 4925 c2 (REV 12-2015) PAGE 5


Application for Voluntary Disclosure
Purpose yy If the applicant is a trust, the trust must have:
yy Never performed administration activities in California
Franchise Tax Boards (FTB) Voluntary Disclosure Program (other than activities that were inconsequential to overall
(VDP) encourages qualified taxpayers with an unfulfilled trust administration).
California franchise/income tax return filing requirement and yy Had no resident beneficiaries (other than a beneficiary
unpaid tax or fee liability to voluntarily come forward. Our VDP whose interest in that trust was contingent) for the six tax
applies to qualified entities, qualified shareholders, qualified years ending immediately preceding the signing date of
members, and qualified beneficiaries. In exchange, we are the voluntary disclosure agreement.
authorized by statute to limit the imposition of tax and fee
liabilities to a six-year period immediately preceding the signing A beneficiarys interest is not contingent if the trust has
date of a voluntary disclosure agreement, and to waive specified made any distribution to the beneficiary during the six tax
penalties (see Penalties Waived). years ending immediately before the signing date of the
voluntary disclosure agreement.
General Information Even if an applicant meets the above criteria, it will not be
considered a qualified entity and will not be eligible to participate
Revenue and Taxation Code (R&TC) Section 19191 authorizes in the VDP if it is any of the following:
us to enter into a voluntary disclosure agreement with any yy Organized and existing under the laws of California.
qualified taxpayer who applies to participate in the VDP to get yy Qualified or registered with the California Secretary of State.
voluntary compliance with the income/franchise tax laws of the yy Maintained and staffed a permanent facility in California.
state of California. Qualified taxpayers who participate in the (Storing materials, goods, or products in a public warehouse
VDP must file tax returns for the six years immediately preceding pursuant to a public warehouse contract does not constitute
the signing date of the voluntary disclosure agreement. We maintaining a permanent facility in California.)
may waive most penalties associated with any tax returns filed.
As part of the voluntary disclosure agreement, we waive our
authority to assess tax, additions to tax, fees, or listed penalties Qualified Shareholders
for tax years ending prior to the six tax years covered by the A qualified shareholder is an individual who is all of the following:
voluntary disclosure agreement.
yy A shareholder of an S corporation that applied for a voluntary
Qualified taxpayers who enter into a voluntary disclosure disclosure agreement.
agreement must fully disclose all material facts pertinent to their yy A nonresident on the signing date of the voluntary disclosure
franchise or income tax liability. In addition, applicants must agreement.
file all tax returns and pay all taxes, fees, and penalties not
waived associated with the tax years covered by the agreement Important Information
within 30 days of the signing date of the voluntary disclosure Applicable penalties will not be waived for any tax years before
agreement. We may extend the time for filing tax returns and the signing date of the agreement in which the shareholder was
paying amounts due to 120 days from the signing date of the a California resident. Penalties or additions to tax attributable
voluntary disclosure agreement, or to the latest extended to income other than California source income from the S
due date of the tax return for a tax year for which relief is corporation filing the application for voluntary disclosure will not
granted, whichever is later. Failure to adhere to the terms of the be waived.
agreement renders the agreement null and void.
A unitary group of corporations is not a qualified entity. Each Qualified Members
corporate member of the unitary group must file a separate A qualified member is an individual, corporation, or LLC that is
application. If multiple corporations in a single unitary group all of the following:
are seeking voluntary disclosure relief, they should submit their
yy A member of an LLC (other than one classified as a
applications simultaneously to the extent possible, and reference
corporation) that applied for a voluntary disclosure
each entitys relationship to the other entity applicants (e.g.,
agreement. If that member is itself an LLC, its members also
parent, subsidiary, etc.) on Exhibit A of their application.
may apply to be treated as qualified members if they meet the
criteria of this section.
Qualified Entities yy In the case of an individual, is a nonresident on the signing
Only qualified entities are eligible to participate in the VDP. A date of the voluntary disclosure agreement.
qualified entity meets all of the following criteria: yy In the case of a corporation or LLC, is not any of the following:
yy It is a qualified entity as defined by statute: a corporation yy Organized under the laws of California.
(including an S corporation), limited liability company (LLC), yy Registered with the California Secretary of State.
or trust. Important Information
yy It is an entity, including any predecessor to the entity, that Applicable penalties will not be waived for any tax years before
previously never filed a tax return with FTB. the signing date of the agreement in which an individual
yy It has not been the subject of any FTB inquiry with respect to member was a California resident. Penalties or additions to tax
any potential liability for taxes or fees. attributable to income other than California source income from
yy It voluntarily came forward, prior to any contact initiated by the LLC filing the application for voluntary disclosure will not be
us, and makes both an application for a voluntary disclosure waived.
agreement and a full and accurate statement of its activities
in California for the six immediately preceding tax years.

FTB 4925 c2 (REV 12-2015) PAGE 6


Qualified Beneficiaries yy Pub. 1060, Guide for Corporations Starting Business in
California
A qualified beneficiary is an individual who is all of the following: yy Pub. 1061, Guidelines for Corporations Filing a Combined
yy A beneficiary of a qualified trust who applied for a voluntary Report
disclosure agreement that disclosed all material facts yy Pub. 1067, Guidelines for Filing a Group Form 540NR
pertinent to the beneficiarys liability. yy Pub. 1083, Frequently Asked Questions About California
yy A nonresident on the signing date of the voluntary disclosure Corporation Taxes
agreement and a nonresident during each of the six tax
years ending immediately preceding the signing date of the To Get Forms and Publications
voluntary disclosure agreement.
Web
Important Information Go to ftb.ca.gov and search for the form number to find the
Applicable penalties will not be waived for any tax attributable forms and publications mentioned in this application.
to income other than income of the trust filing the application for
voluntary disclosure. Mail STATE OF CALIFORNIA
TAX FORMS REQUEST UNIT MS D120
FRANCHISE TAX BOARD
Penalties Waived PO BOX 307
If the qualified entity, qualified shareholder, qualified member, or RANCHO CORDOVA CA 95741
qualified beneficiary fully complies with the voluntary disclosure Phone 800.852.5711 from within the United States
agreement, FTB may not assess any of the following R&TC 916.845.6500 from outside the United States
section penalties for the tax years covered by the agreement: TTY/TDD: 800.822.6268 for persons with hearing or
yy Section 19131 Failure to make and file a tax return. speech impairments.
yy Section 19132 Failure to pay any amount due by the date Additional Assistance
prescribed for payment. Call 916.845.4476 for questions about the VDP.
yy Section 19136 Underpayment of estimated tax.
yy Section 19141 Secretary of State penalties imposed
pursuant to Corporation Code Sections 6810 and 8810(a). Franchise Tax Board Privacy Notice
yy Section 19141.5 Failure to furnish information or maintain To learn more about your privacy rights, how we may use your
records. information, and consequences if you do not provide information
yy Section 19142 Underpayment of tax. we request, go to ftb.ca.gov and search for privacy notice. To
yy Section 19172 Late filing of partnership tax returns. request this notice by mail, call 800.338.0505 and enter form
yy Section 19183 Failure to file information tax returns. code 948 when instructed.
yy Section 23305.1 Contract voidability. Relief from contract
voidability will be granted to a qualified entity when the terms
of the voluntary disclosure agreement are fulfilled. Instructions for Filing Form 4925,
Application for Voluntary Disclosure
Violation of the Agreement Complete FTB 4925, Application for Voluntary Disclosure, to
The voluntary disclosure agreement is null and void if the participate in the VDP. Each application pertains to only one
qualified entity, qualified shareholder, qualified member, or qualified entity (the primary applicant) and to any qualified
qualified beneficiary: shareholders, qualified members, and qualified beneficiaries that
are applying for voluntary disclosure relief in conjunction with the
yy Misrepresents material facts relating to the agreement. primary applicants application (secondary applicants).
yy Fails to file any tax return or pay in full any tax, penalty, or
interest for the periods covered by the agreement within the Application Part 1
time prescribed. To apply anonymously, an applicant may have an authorized
yy Fails to comply with an installment payment arrangement. representative contact us. The representative should not reveal
yy Fails to begin to prospectively comply with all franchise and the name of the applicant or any information that would readily
income tax laws of this state. identify the applicant to us until the agreement is executed.
yy Understates the tax liability for any year covered by the We assign these applicants an identifying number, such as
agreement by more than 10 percent and cannot show a good Anonymous 15-001, to use for subsequent correspondence.
faith effort to accurately compute the tax liability.
If the applicant does not wish to apply anonymously, the
applicant enters its name, address, and telephone number.
Forms and Publications The applicant may be represented by a third party by providing
yy Form 100, California Corporation Franchise or Income Tax FTB 3520, Franchise Tax Board Power of Attorney Declaration,
Return authorizing such representation.
yy Form 100S, California S Corporation Franchise or Income Tax Application Part 2
Return Answer each question. If the applicant answers Yes to any of
yy Form 100W, California Corporation Franchise or Income Tax the questions, the applicant does not qualify to participate in the
Return - Waters-Edge Filers VDP.
yy Form 540NR, California Nonresident or Part-year Resident
Income Tax Return If the applicant answers No to all questions, provide the
yy Form 541, California Fiduciary Income Tax Return additional information requested.
yy Form 568, Limited Liability Company Return of Income Each applicant entity should complete the relevant entity-specific
yy Pub. 1050, Application and Interpretation of Public portion of the application or we will consider the application
Law 86-272 incomplete and may deny it on that basis.

FTB 4925 c2 (REV 12-2015) PAGE 7


Application Part 3 Application Part 6
Only complete this section to provide information related to a Provide the following information and attach it to the application
qualified shareholder of an S corporation applicant. Provide the as Exhibit A:
following statements: 1. Applicants state of incorporation/organization.
1. How many shareholders held an interest in the qualified 2. Applicants line(s) of business and business activities inside
S corporation applicant. Of those, state how many are and outside California.
individuals and if all individual shareholder applicants are 3. The tax year applicant began doing business anywhere.
currently nonresidents. 4. The business activities creating California nexus and tax year
2. How many qualified shareholders are applying for the VDP. it was created.
3. The reason why any shareholders are not applying for the 5. If applicant is a unitary group member, its relationship to other
VDP. applicants.
4. Whether the S corporation will be filing a group nonresident 6. The applicants accounting period beginning and ending
tax return for its shareholders (see Pub. 1067). dates.
5. The basis as to why the qualified shareholders believed they
were immune from California tax.
Application Part 7
6. If the shareholders relied on advice indicating they were For each applicant, provide the estimate of California tax
immune from California tax. due for each tax year at issue, along with all other requested
7. Other information attesting the qualified shareholders good information, and attach it to the application as Exhibit B.
faith and lack of willful neglect in failing to file California tax Application Part 8
returns and pay California taxes.
Provide your signature to acknowledge that you:
Application Part 4 yy Understand the consequences of providing an incomplete
Only complete this section to provide information related to statement.
qualified members of an LLC applicant. Provide the following yy Declare that you are the applicant or an authorized
statements: representative, applying for the VDP.
1. How many members held an interest in the qualified yy Provided true and correct information to the best of your
LLC applicant. Of those, state how many are individuals, knowledge.
corporations, or other LLCs, if all individual member
applicants are currently nonresidents, and if all corporation Mailing Application to FTB
and LLC applicants are not organized under the laws
of California and are not qualified or registered with the Applications to participate in the VDP must be in writing. If you
California Secretary of State. use U.S. regular mail (including U.S. standard postage stamp
2. How many qualified members are applying for the VDP. mail, U.S. priority mail, U.S. certified mail, U.S registered mail,
Of those, state how many are individuals, how many are and U.S. insured mail), mail FTB 4925 and required exhibits to:
corporations, and how many are LLCs. STATE OF CALIFORNIA
3. The reason why any members are not applying for the VDP. VOLUNTARY DISCLOSURE PROGRAM MS F180
4. The basis as to why the qualified members believed they FRANCHISE TAX BOARD
were immune from California tax. PO BOX 1779
5. If the members relied on advice indicating they were immune RANCHO CORDOVA CA 95741
from California tax. If you use a private express mail carrier (including Federal
6. Other information attesting the qualified members good faith Express, United Parcel Service, and DHL, but excluding any
and lack of willful neglect in failing to file California tax returns form of U.S. regular mail), mail FTB 4925 and required exhibits
and pay California taxes. to:
Application Part 5 STATE OF CALIFORNIA
Only complete this section to provide information related to VOLUNTARY DISCLOSURE PROGRAM MS F180
qualified beneficiaries of a qualified trust applicant. Provide the FRANCHISE TAX BOARD
following statements: 9646 BUTTERFIELD WAY
SACRAMENTO CA 95827
1. How many beneficiaries held an interest in the qualified trust
applicant. Of those, state how many are individuals, and if all We will contact the applicant or its representative if additional
individual beneficiary applicants have been nonresidents for information is required.
the past six years.
2. How many qualified beneficiaries are applying for the VDP.
3. The reason why any beneficiaries are not applying for the
VDP.
4. The basis as to why the qualified beneficiaries believed they
were immune from California tax.
5. If the beneficiaries relied on advice indicating they were
immune from California tax.
6. Other information attesting the qualified beneficiaries good
faith and lack of willful neglect in failing to file California tax
returns and pay California taxes.

FTB 4925 c2 (REV 12-2015) PAGE 8

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